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Package of Applications for Renewal & Amends to License 12-00722-06

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Package of Applications for Renewal & Amends to License 12-00722-06 - .. ..:. - O , . Mr s. Petet dua/ ; e AV 7M-3u831 'b- .f . DEPARTMEN1 OF THE ARMY HE A DQu A R TE R>. us ARMY ARMAMENT M A T E RiE L RE AD NESS COMMAND ROCK ISL A N D. ILLINOIS 41299 gh[- s , . m cf "'~~ " 0 8 JUN 1983 SlbJECT : Nuclear Regulatory Curnmission (tEC) Request for AJOlti.sn el Infotn otico in Sippor t of Renewai Appilcoticr. for By-Pluduct Motelial License 12-00722-06 Cui.iios ee. US Aln.y Materli.1 Develupn.eiit arJ Result.e>> Cuic.ord 'ATir4: Ci<C . /-P 1. Rer et. .i t e A c t *.e; , Dr.t5F -P, HQ, GAhtoM, e Aps li 19c3, sad. 2. The tvilu.ing :ept ies are provided to tre lequest from f(C, .'s k%:ch . O, witn Control huncer Iz3e3. a. H-t;sest i: Clatify the type of perloalc raciaticri sorse,s that mill be ccrou tea to t. ii6 air.ter rice sna bulk stcruge facilities. P eese cuifirm tt ; tnic,,e ut wjs .111 us.sist of instrument oro smeer testing surveys. P, .,3e sat i t f the estani! , t;co li,r,its that are acceptacle uruer the sc. car s i. .cf P.. i er.. F.uc lef t.I to Regsletory Guiae 8.21 (copy enti/Jaeo). You ino, to t e: t">e t . i te: 1, .;: . c , !r To Q s 1 and 2 cf this guide ni4 oe f3 :so.ec. P;e.:sr v .f i. 4, y .it sof,ty insticctions will be fr.Cdit :cd to le c. sce tr.i t. ct;Letis. # m .s.,on ; At'. y e coulati,.,n (fc 700-64) Itwiles monit..r '. y at t.ulk : Lot / .w.iLicos to cua.rt cf Cu.a. telly sut seys using opp;i9; T. ale M i : lit.ac J. ..r s: U .: tax ar., . i t o: cum cr< art erd e'.41uot ing ti.eti.. Unce; the $ plesent 41 00 74.:-Cr. ilce i>,. ur.cor s are Lamen An ouln stu. age IGcsLionG g munthly oou evoluateu ti/ ilt;alu scintillation countitg for tritiuui. Action , level is @ cpm /louctrd, f 4 I' o. Hzitesti 2: Ptuw:oe a copy cf (ne iristtt.ctions ta persc.):ici piLxing w. rect s..sy. oia tureir.: poc % ed vt raa'coctive mate:ials anc confirm tnot . ~, you wi G t 1.u. Luc piecedules given in 20.;0$ uf 10 LTr4 Part 20. .* hc . pt. id :: HImf HotJJ1otico 700-04, p31 5-6, R Jioactive Commoaaties in the (NJ Supply 5, s teins stire: 1), oru AR 38.1, para 1-22, lunizirg Raciatleris Prctc;. 641 (t rt '. .:), define respuislulletics for picato, regelpt, , are cpenil..y cr ps.,... .es cur.t.aning radioact ive iaotet tai 2. This iriformation -- | 8510180402 851011 i PDR FOIA FLECKEN85--593 PDR < . - .__ _ _ _ _ _. * . -. ' . '? W -SF T'~ | Sud.]EC T : ftJclear Regulatory Commission (mC) Request for Additional Information in S@polt of Renewal Application for By-Procuct Material License 12-00722-Oo is usually further s@plemented by a local standard operatirig procedure at the particular Army installation. ARRCOM health physicists annually inspect , bulk storage locations which store tritium devices unoer the 12-0072-04, Oo,. ! and 09 license. Du11ry these inspections the adequacy of fulfliling tne abuve rujslations is cetermined and corrective measures instituted as required. The Army regulations follow the procedures given in 20.205, 10 CFR Part 20. ! c. Request 3. * Unoer yout proposed bloassay program, please clarify the concitiuns urcer which the Army will conduct tritium bioassays. Ir R.-sponse: - The Army conoucts tritium bioassays at those depots and Ruck Island Arsenal which are cesignateo locations for rework of equipment wnien conto'n the vials. Personnel wno wcrk with tritium have a baseline urinalysis taken at start or work ano monthly thereaf ter. If an incioent j witn tritium xcurs, urinalysis for tritium is done at that time. 4 J. Request a: With respect to the quality assurance ptogram for contaninatitn testirg of the raoloactive sources and related subassemblies, i ple >e c,od f y the aloe test contamination limit acceptable to the Army in terms of Jis./ min./Ctr.2 Uf area tested (please specify) . i he gur.: e : ; | (a) ine p esent lin.it statec cn dra ir9. of sources suomitted for j tr.e license is "te%vahe raviological contamination by wiping snoll be less thun 1,000 epos." inis limit of removable cont. amination has been appliec as J | 1,000 cpn.s per source legaluiess of the exact size of the source. ' The M sur f ace aien of sonne sou ces is under 100 cm2 y 30) The limit of 1,000 opms terravable contamination per source, where N . ' t the source has a smaller surface area than 100 cm2 is still far below the J alle atle contamination level. The total t,ooy burcen for tritium is 2 mci e ; (IRCP han h ok). 2 mci a 4.44 x 109 dpm. * If a worker were to ingest the maximun allunable contr,mination of 1,000 dpm per source per minute, it would '3 , | take 1,850 40-hcur work weeks or 9,250 8-hour work oays to re.ch the tritium g- i j ' cocy ouruen. This assurr.es toximun allowable coritomination and a constant g irgestion rate of 1,000 epm per minute. This oces not take into account the i biologica. nalf-lif e of tritium, i.e.,16-18 days. It is apparant that the j 1,000 cpm limit per source n111 not present a hazard to the user in excess of ' allowable 11 nits. (c) AJuitionally, we requested in a letter cated 14 May 1982 and hano cat tled to the MC, that the teracvable euntamination level be set at 2,000 opm/100 cm2 for surraces of equipment in which sources are installed. Usito the sone justificottui as above, it 2,000 dpm were irgested per minute ! constantly, it would take 925 40-hout work weexs to reach the maximum tritium ' i * ) ! i _ . _ ._ _ . _ . _ . _ . _ _ - - _ _ ~ . _ _ . _ . _ _ _ _ . , - - - _ . - . _ . _ _ _ . _ _ - . _ . _ _ . _ . ~ , f . - . | ' OR$AR-SF SEJECT: N clear Regulatory Commission-(t@C) Request for Additional I Information in Stoport of Renewal Application for By-Product ' Material License 12-00722-Oo , body buiden. This is not taking into account the biological half-life of f tritium, i.e. ,16-18 days. We request that the contamination level be raiseo j to a masimum 2,000 dpm/100 cm2 for surfaces in which soulces are ; installed. This limit is required to prevent losses of expensive equipment ; which cannot be reasonaoly decontaminated below the prestated limit. ; (c) Use of equipment decuntaminated to the 2,000/100 cm2 level 111 be controlled to field use =lthin the 000. Equipaunt planned for release out:.loe tr.e 000 will be decontaminated to 100_dpm/100 cm2 as stateq_Ln_ t_he , liceru.e wplication. 6 - - . - . - 3. Annidun Army Depot had been listed on the 12-00722-06 lice.La as a bulk ; storage and oepot level maintenance f acility. However, the rene al request | * tu the 12-C0722-06 license listeo Anniston only as a bulk storage facility. [ , Rescat en.dston be listed as BOTH o Dulk storage area una deput level | mainter.oxe facility. Attached are the Depot 50P for Handling Tritium, Resuw for tr.e RPG, ano Recult Roum Leyout (Ercl 3, 4, 6nd 5). ' 4. Point of c.cr.tatt at tn! _ of fice ore Mrs. Betty Peter son and ; Mrs. Katt,y LaFrenz, AUTUv0N 793-34bt/FTS 367-3482. FUa le{ Oc % zee: i 5 tra:1 LdwfttdC E. SHliH as Cniet , Safety Of fice ;r i n > '5, . 8 1 | ! t . 3 | | j li e N k ! ' I ! I \ 4 ! ; ! ! f | | | i i i ' ' 3 k ( t . .I . r> , ' . , - * . g . ' DSAM 4145.8 . AA 700-64 , NAVSUFINST 4000.34A , , Allt 67 8 , MCO F4400.1058 . * I ' ' 5-4 FAcxACINC * a. When it is necessary to repackage radioactive cosanodities because of loose issue or damage to the original containct, the coninodity shall be repackaged in accordance with inattuctions in the directives or regulations cited in paragraph 5 2 or to conform t with the original package. The oristnal container shall be opened and repacked care- * j fully, and shall be monitored. Packaging and rapacking operations, including monitor. * * . ing, shall be carried out in a controlled area in the presence of qualified radiation * protection personnel. b. Containers shall be marked and labelled in accordance with MIL-STD-1458 and DSAM , 4145.J/AFM 71-4/TM 38-250/NAVSUP PUB 305/HC0 P4030.19. o . 5 5. OTHER SHIPwE*C5. References cited in paragraph 5-2 above, regulates shipment of ~ radioactive conunodities by the U.S. Puntal Servise, and Cscunerc tal Carrier originating in the United States. The International Ato.nic Energy Agency and International Air Transport Association regulations are used of ten by foreign governments and for over- seas -tir transport. 5 6. PICElvtNC AcTtvt1Y RESPONSIBit.!T tES , s. Receiving activities shait establish procedures for the pickup, receipt, aonitor- ing, opening. recording, and reporting radioactive coannodity shipments in accordance . - * with Title 10. CFR, sections 20.205 and 20.401. T b. As soon as a radioactive consuodity is located in an incondog shipment, it shall f be cionitored with appropriate instruments to determine existence and magnitude of radiation hazards.
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